Summary

  • RIPE policy proposal 2024-01 entered Review Phase on 25 August 2026 and remains open for discussion until 23 September; it has not been adopted or implemented.
  • Proposed section 2.6 would treat a bounded same-geographical-End-Site use of a /56 or longer prefix by another entity as something other than a prohibited sub-assignment.
  • Current section 7.2 restricts PI assignments held by an LIR to the LIR’s own infrastructure, excluding customer End Sites. RIPE NCC’s impact analysis says an End User that later becomes a member would make the previously permitted sub-assignments non-compliant.
  • The missing governance object is a dated membership-transition receipt joining the unchanged network use to the old and new policy classifications, notice, remediation and final outcome without exposing customers or topology.

The packet path need not change

Imagine an End User with an IPv6 PI assignment. A customer appliance sits inside the holder’s network at the same geographical End Site. It receives a persistent prefix that fits the conditions described in the proposed wording of section 2.6. Then the End User pays its invoice, returns a signed Standard Service Agreement and has its LIR account activated.

No cable moves. No router is replaced. No prefix changes hands. No new customer appears. Yet the RIPE NCC’s own impact analysis for proposal 2024-01 identifies a possible legal-operational change: once the End User becomes a member, those sub-assignments would no longer comply with section 7.2.

That is a compliance event produced by institutional status rather than network behaviour. It deserves to be recorded as such. Otherwise an audit performed after membership activation can describe the arrangement as non-compliant without preserving the fact that the same arrangement occupied a different category the day before.

The distinction is not an argument against membership. It is an argument for a transition rule that can be inspected.

Section 2.6 creates a narrow permission

The draft policy document would revise the definition of “assign.” Its proposed section 2.6 continues to prohibit full or partial sub-assignment to another entity, but carves out a bounded case. Connectivity to another entity within the assignment holder’s network, at the same geographical End Site, using a /56 or longer prefix would not be treated as a sub-assignment. The text gives examples including persistent addressing for a connected server or appliance and certain point-to-point links.

The permission is not unlimited hosting authority. Remote customer End Sites remain outside it, and the wording attaches significance to geography, network custody, prefix length and routing purpose. RIPE NCC’s impact analysis also notes that “geographical End Site” is not strictly defined and asks whether the relevant unit is a country, city, address or building.

Those ambiguities matter, but they are not the event examined here. Hold every one of those facts constant. Assume the arrangement qualifies while the holder remains an End User. The next question is what happens when the holder’s institutional role changes.

Section 7.2 changes the predicate

The current IPv6 Address Allocation and Assignment Policy, ripe-738, says PI cannot be further sub-assigned to other organisations. Section 7.2 then gives LIRs a narrower qualification: they may hold IPv6 PI for parts of their own infrastructure that are not used for customer End Sites. If the original criteria are no longer valid, the LIR should return the PI assignment within six months.

Proposal 2024-01 does not provide a finished bridge between the new section 2.6 exception and this LIR-specific boundary. The impact analysis states the consequence plainly. It reads the proposal as allowing End Users to create certain sub-assignments from PI blocks, then says that if an End User decides to become a member, those sub-assignments would no longer comply with section 7.2.

Membership is therefore not merely a billing or participation attribute in this fact pattern. It selects a different policy predicate. The holder moves from “End User using the section 2.6 exception” to “LIR whose PI may not serve customer End Sites.”

The public membership process supplies a potentially auditable timestamp. RIPE NCC says that after it receives payment and the signed SSA, it activates the LIR account. That activation is more useful than an imprecise label such as “became a member sometime this month.” It can anchor the before-and-after classification.

Existing guidance makes the boundary tangible

RIPE NCC’s current IPv6 PI request guidance already distinguishes an individual address from a subnet. It permits uses such as connecting a customer server or appliance where each device receives a separate address, while saying the holder may not assign a prefix—even a /64 or /96—to another entity under the current rules.

The proposal attempts to modernise that line by permitting bounded prefix use at the same site. The impact analysis then reveals that the holder’s later role can move the line again. An operator looking only at the route, inet6num object or rack layout may miss the decisive fact, because the decisive fact is the effective time of LIR status.

Nor is the sponsoring-LIR relationship enough to answer the question. RIPE NCC’s independent-resources guidance explains that an End User obtains PI through a sponsoring LIR and maintains a contractual relationship with it. The End User is not thereby the LIR. A later decision to join RIPE NCC creates a different relationship and, under the impact analysis, a different compliance test.

A transition receipt should join status to use

A defensible receipt begins with an immutable PI assignment identifier and the legal entity holding it. It records the exact policy text and version used for each assessment. It does not need a public inventory of customers. A privacy-safe aggregate can say whether one or more same-site external-prefix arrangements exist and which permitted-use class they occupy.

The centre of the record is membership_lir_effective_at: the time the LIR account became active. The receipt then places a section 2.6 assessment immediately before that point and a section 7.2 assessment immediately after it. Each result names the accountable decision-maker, the evidence class considered and any unresolved geographical or routing condition.

If the new status creates non-compliance, the record should not jump straight from classification to punishment. It should show when notice was delivered, whether the holder may migrate the customer use to allocated space, obtain upstream space, renumber individual devices, amend the arrangement, or return the PI assignment, and which clock applies. The outcome—resolved, exception pending, disputed, still open or subject to another procedure—belongs in a separate field with correction history.

This is less disclosure than a case file and more accountability than a retrospective label. It lets a holder, sponsor, auditor and RIPE NCC distinguish a new breach from a status-triggered reclassification.

Review is still open

The current-proposals page records 2024-01 in Review Phase from 25 August to 23 September 2026. The Address Policy Working Group thread shows participants already identifying the section 2.6/7.2 inconsistency. At the end of the phase, the chairs assess rough consensus.

None of that proves adoption. It proves that the transition defect is visible while the text is still contestable. The appropriate conclusion is correspondingly narrow: if the policy preserves a membership-triggered change in compliance, the implementation needs an explicit temporal bridge. If the text is repaired so the category no longer flips, the receipt can record that versioned result instead.

Sources